FinCEN Postpones Residential Real Estate Reporting Requirement Until March 2026

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FinCEN announced today that the reporting requirements for the “Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule” (RRE Rule) have been postponed until March 1, 2026. The previous deadline was Dec. 1, 2025, for a new anti-money laundering rule that requires reporting for specific all-cash residential real estate transactions involving legal entities and trusts to the U.S. Department of Treasury’s Financial Crimes Enforcement Network.

In a press release, FinCEN officials acknowledged that the agency is postponing the deadline to provide the real estate industry with more time to comply, to reduce business burden, and to ensure effective regulation. FinCEN has issued a temporary order granting exemptive relief from the reporting requirements.

In August, FinCEN introduced the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule, which does not apply to transfers made directly to individuals. It is triggered only when the transferee is a legal entity (such as a corporation, LLC, partnership, or estate) or a trust. All-cash and non-bank financed transactions are the primary focus of the new rule as they present higher risks for money laundering.

The new rule directly impacts a range of real estate professionals and businesses involved in closings and settlements, including settlement agents, title insurance companies and agents, escrow agents, attorneys involved in closings, and other professionals performing specified functions in the transfer process.

Real estate professionals involved in closings must identify the reporting party, collect detailed beneficial ownership information, and file reports within 30–60 days. FinCEN has published the Real Estate Report Form that now must be submitted by March 1, 2026. FinCEN has also published a fact sheet and FAQs on the new rule.

Read our alert published last month that details various requirements within the new rule such as what constitutes a reportable transfer, who is the reporting person, what must be disclosed, and what transactions are exempt and not reportable.

All professionals involved in closings and settlements of residential real estate to entities or trusts should familiarize themselves with the rules, review their transaction processes, update closing documentation, assess their exposure, and prepare for reporting and recordkeeping obligations to ensure compliance by the new effective date of March 1, 2026.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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